Meachum v. Fano

Supreme Court of the United States · 1976 · Administrative Law

Administrative LawDue ProcessPrison TransfersLiberty InterestsDue Process ClauseFourteenth Amendmentliberty intereststate-created liberty

Facts

After a series of serious fires at the Massachusetts Correctional Institution at Norfolk, six inmates were removed from the general population and brought before the prison Classification Board to determine whether they should be transferred. They received notice that prison authorities had information linking them to criminal conduct, and hearings were held at which the superintendent gave in camera testimony based on informants; the inmates could present evidence but were not given the details of the informant information. The Board recommended transfers of several respondents to Walpole, a maximum-security institution with substantially less favorable living conditions, and one to Bridgewater; prison officials approved most of those recommendations. The transfers did not involve loss of good time or disciplinary confinement, and Massachusetts law did not condition transfers on proof of misconduct or any other specified event.

Issue

Does the Due Process Clause of the Fourteenth Amendment require a hearing before a state prisoner may be transferred to another prison with substantially less favorable conditions when state law or practice does not condition such transfers on proof of serious misconduct or the occurrence of other specific events?

Rule

The Due Process Clause does not itself protect a duly convicted state prisoner from transfer to another prison within the state system, even if the new institution has substantially less favorable conditions, because confinement in any of the State's prisons is within the normal range of custody authorized by the conviction. Procedural due process is required only when the prisoner is deprived of a liberty interest, and a state-created liberty interest arises only when state law substantively limits official discretion by conditioning the deprivation on specified misconduct or events.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Omar Reyes is serving a valid state sentence in Ohio at a medium-security prison near Dayton. The corrections director transfers him to a maximum-security prison in Youngstown with stricter visitation rules and less recreation, under a statute allowing transfers among state prisons whenever officials consider them appropriate.

Does the Fourteenth Amendment require Ohio to provide Omar a hearing before the transfer?

Explanation. The majority held that the Due Process Clause does not itself give a convicted prisoner a liberty interest in remaining at a particular prison within the state system. Even if the receiving prison has substantially less favorable conditions, no hearing is constitutionally required where state law permits transfer in officials' discretion and does not condition transfer on specified misconduct or events.